Privacy Policy
This privacy policy aims to facilitate information regarding BODEGAS ELOSEGI, S.L.’s processing of personal data and to describe any interested parties’ rights under the (EU) Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and under the Organic Law 3/2018 of 5 December on Personal Data Protection and guarantee of digital rights (LOPDGDD).
1. Controller identity and contact details
BODEGAS ELOSEGI, S.L., with CIF [Spanish Tax Code]: B-20533493, is responsible for processing the data listed below. They can be contacted through the following channels:
- By post, to: Polígono 201, C.P. 20212 - Olaberria (Gipuzkoa, Spain).
- By email: bodegaselosegi@bodegaselosegi.com
2. Data processing: description of the purposes, legal bases and recipients
BODEGAS ELOSEGI, S.L. has Records of Processing Activities of which it is the Controller, and that list the purposes of the processing, the legal bases on which they stand, and the other elements envisaged in art. 30 of the GDPR. The data processing carried out through this website are mentioned below, along with other details related to the website activities:
Processing | Purposes of data processing │ Legal standing │ Recipients |
---|---|
Candidatures | |
Purposes | Management of personnel recruitment processes. |
Legal standing | Consent of the interested party |
Recipients | Personnel recruitment companies |
External personnel | |
Purposes | Management, control and supervision of personnel sent by temporary employment agencies. |
Legal standing |
- Fulfilment of legal obligations - Execution of a contractual relationship |
Recipients |
- Workers’ legal representatives - Source temporary employment agency |
Clients | |
Purposes | Integral management of the relationship with clients and potential clients, including orders, invoicing, payment, commercial management, accounting, taxes and administration, and communications maintenance. |
Legal standing |
- Fulfilment of legal obligations - Execution of a contractual relationship - BODEGAS ELOSEGI, S.L. has a legitimate interest regarding the processing of contact details for natural persons who provide a service in legal entities and for individual employers and independent professionals |
Recipients |
- Tax administration - Banking institutions - Accounts auditors - Tax consultants - Carriers - Distributors - Management software supplier (ERP) - Computer maintenance supplier |
Suppliers | |
Purposes | Integral management of the relationship with suppliers and potential suppliers, including orders and offers, invoicing control, payments, accounts management, taxes and administration, and communications maintenance. |
Legal standing |
- Fulfilment of legal obligations - Execution of a contractual relationship - BODEGAS ELOSEGI, S.L. has a legitimate interest regarding the processing of contact details for natural persons who provide a service in legal persons and for individual employers and independent professionals |
Recipients |
- Tax administration - Banking institutions - Accounts auditors - Tax consultants - Management software supplier (ERP) - Computer maintenance supplier |
Board members and Partners | |
Purposes | The management of partners’ and board members’ details to fulfil all obligations derived from commercial legislation, including the duty to keep a register/book of partners, minutes book, a record of having sent notice of calls and of carrying out all mandatory notifications and registrations at the Register of Companies. |
Legal standing | Fulfilment of legal obligations |
Recipients |
- Register of Companies - Accounts auditors - Notaries - Legal consultants |
Communication and Marketing | |
Purposes | Management of the company’s communication and marketing activities, including dealing with queries, requests for information and suggestions, sending out a newsletter, publishing images of personnel on the web page, and the dissemination of information on social media. |
Legal standing |
- Consent of the interested party - Art. 21 of the Law 34/2002 regarding sending electronic commercial communications |
Recipients |
- Hosting supplier and web page users - Web page content management company - Social media suppliers (USA) |
Video-surveillance | |
Purposes | Capture, recording and viewing of images using security cameras at the premises. |
Legal standing | Fulfilment of a public interest mission |
Recipients |
- Competent authorities where applicable - Maintenance company |
Visit monitoring | |
Purposes | Control of visitor access to the factory. |
Legal standing | Legitimate interests of the data controller for security reasons. |
Recipients | The data will not be passed on to third parties, except where required to do so by law. |
3. Data retention
Every time data is processed, it will be kept while the established relationships are ongoing, and subsequently during the legally applicable periods and the necessary time to be able to fulfil the purpose for which said data was compiled, and to determine any possible responsibilities that may derive from that purpose and from the data processing. When the data processing in question is based on consent, the data will be retained until said consent is revoked or a request is received to delete said data. Only the necessary data for each process will be requested, so any failure to communicate details will mean the established relationships will not be able to be maintained or the requests received will not be able to be answered.
4. International data transfers
In the case of posting images of people and/or videos on Facebook, Instagram and/or Twitter, the data will be internationally transferred to Facebook Inc. and/or Twitter Inc., respectively. Said entities are based in the USA and are covered by the EU-US Privacy Shield agreement, so the transfer in question is protected by an adequacy decision by the European Commission.
5. Exercise of rights
By writing to our postal address or by email: bodegaselosegi@bodegaselosegi.com, the interested party, or the owner of the personal details in question, may exercise the following rights, in the circumstances and conditions envisaged in current regulations:
- Right of access: to find out whether or not their data is being processed.
- Right to rectification: to rectify any inaccurate data.
- Right of erasure: to stop the data being processed when, among other reasons, said details are no longer necessary for the purposes for which they were collected.
- Right to object: to stop the data being processed in specific circumstances.
- Right to restriction of processing: to restrict the scope of their processing in given cases, but ensuring their retention.
- Right to data portability: to receive the data that had previously been provided or to request it be sent to a third party.
- Right to revoke any previously given consent at any time.
- Right to make a complaint before the supervisory authority to enforce their rights.
To exercise their rights, the interested party must provide a copy of the official document giving proof of identity.
6. Updated Privacy Policy
The content of the data protection policy may be subject to modification to ensure it meets any legislative changes that may arise, as well as to adapt to criteria and positions issued by the supervisory authorities.
The Privacy Policy was updated for the last time on 31/01/2020.